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are frivolous and/or groundless.7 We also conclude from the
record that petitioner has instituted and maintained this
proceeding primarily for delay. Accordingly, pursuant to section
6673, we require him to pay to the United States a penalty of
$2,500.
We have considered all arguments and have found those
arguments not discussed herein to be irrelevant and/or without
merit. To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
7 The Appeals officer directed petitioner’s attention to our
decision in Pierson v. Commissioner, 115 T.C. 576 (2000), wherein
taxpayers advancing frivolous and groundless claims and
instituting proceedings under sec. 6330(d) for the purpose of
delay were given an unequivocal warning that the Court would
impose penalties. In addition, petitioner received a copy of our
opinion in that case; that opinion was sent to him by the Appeals
officer after the equivalent hearing.
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